Access to Treaty Benefits

S. VIIPreface

This volume in the “Series on International Tax Law” includes the master’s theses of the full-time students attending the 2020/21 class of the postgraduate LL.M. programme in International Tax Law at WU (Vienna University of Economics and Business). The general topic for this year is “Access to Treaties”. The access to tax treaty benefits is crucial for taxpayers in order to obtain treaty benefits. However, the application and interpretation of the tax provisions of the OECD Model Tax Convention is not always clear and, in fact, can often cause various difficulties. In this context, the BEPS project issued by the OECD has also led to many new provisions regarding the application of tax treaties in the Model Tax Convention. Against this background, given the importance of a comprehensive analysis of the access to Tax Treaties, this volume aims to develop academic insights, provide practical guidance, and enable an in-depth analysis of the specific aspects of this topic as well as to generate new and innovative approaches to issues arising in relation to the scope of the OECD MC.

Part I of this volume is titled “Tax Treaty Interpretation” and contains contributions that deal wi...